Taxpayers have the right to appeal an IRS decision in an independent forum. This is one of ten basic rights — known collectively as the Taxpayer Bill of Rights — that all taxpayers have when working with the IRS.
The IRS’s Independent Office of Appeals that handles a taxpayer’s case must be separate from the IRS office that initially reviewed that case. Generally, Appeals will not discuss a case with the IRS to the extent that those communications appear to compromise the independence of Appeals.